Renee Fleming / Cease & Desist



2/22/2005 3:17:01 PM Eastern Standard Time



Click here to send a message."Zaremski, Robin" <[email protected]>



Click here to send a message."'[email protected]'" <[email protected]>



Click here to send a message."Baisley, Elizabeth" <[email protected]>

  Sent from the Internet (Details)


February 22, 2005
TO: Website:
Re:     RENEE FLEMING/"La Cieca" 
Dear Ladies and Gentlemen:

I am writing on behalf of Universal Classics Group, a Division of UMG Recordings, Inc. ("UCG").  It has come to our attention that website (the "Website") is currently representing on its La Cieca page that an MP3 it is making available for downloading is a recording by the Decca Crossover artist Renee Fleming.  Be advised that Renee Fleming is an exclusive recording artist of UCG, and as such, UCG owns all rights to any recordings by Renee Fleming as well as the exclusive right to use the artist's name in association with recordings.  UCG has not authorized the use of artist's name or the use of any recordings for either commercial or promotional purposes to you or your Website.

Please be advised that your use of artist's name in association with a recording and/or any recording(s) by artist is unauthorized, in direct violation of the rights of UCG, and may result in liability or substantial legal sanctions.  We hereby demand that you take the following actions: 1) immediately cease and desist from any further use of artist's name in association with recording(s) and from distributing or in any other way exploiting recording(s) performed by the artist or alleged to be performed by the artist, 2) immediately remove from your Website any reference to Renee Fleming or Decca in connection with the distribution of any recording(s), 3) confirm to us in writing within three (3) business days that you have taken the foregoing actions and will refrain from further unauthorized uses on your Website.

I await your prompt assurance in writing that you have ceased and will desist from engaging in further unauthorized uses of artist's name, the Decca name, and any references to recording(s) in association with those names.  This letter is not intended to be a complete statement of the law and/or facts in connection with this matter, and UCG expressly reserves all rights, legal, equitable or otherwise, with respect to any claims or actions it may bring under applicable law, whether or not the above-referenced violations of our rights are cured.

If you have any questions concerning this matter, please contact Robin Zaremski at (212) 331-2545 or by email at [email protected].

Very truly yours,

Robin Zaremski
Business & Legal Affairs
Universal Music Group

cc:  S. Gold, C. Roberts, E. Baisley










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